While there is much about the California Consumer Privacy Act that remains unclear (with the continued potential for legislative amendment and expected guidance from the Attorney General), there is also much that is known. With an implementation date as early as January 1, 2020, there are steps companies should be taking now to start their compliance program – and which will help guide and streamline compliance going forward:1. Know Your DataIt is essential to know the data you collect, where (and who) it comes from, how it is organized and where it is stored (often referred to as “data mapping”). Some companies may have done this or a level of this for GDPR or other compliance, others may be starting almost from scratch. This is step 1 for any privacy and data security compliance program and an essential component of corporate risk management: you can’t disclose, manage or protect what you do not know you have. And, don’t forget offline data…
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